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After their chat, Cochran again reminded “Ashley” to clean out her archives.

Subsequent encounters between Cochran and “Ashley” were similar in nature.

Cochran's reliance upon these factors as setting a baseline for what is required to satisfy the second element under § 2422(b) is misplaced.

It is unsurprising that courts have looked to the factors noted by Cochran to satisfy the second element under § 2422(b), particularly when the allegation is that the defendant enticed the minor to engage in illegal, physical sexual contact.

There is no reason, however, to find that these factors constitute a floor on what is required to satisfy the persuasion, inducement, enticement, or coercion element, especially when the underlying criminal sexual activity does not require a face-to-face meeting or physical contact.

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